Nov 20, 2010

Social Security Gives Ground On Standardized Testing; Comment Period On Mental Illness Listings To Be Reopened

The Social Security Administration announced today that it will publish a notice clarifying part of the recently proposed “Revised Medical Criteria for Evaluating Mental Disorders.”

In order to address some public misunderstanding, the notice will better explain how Social Security would consider the use of standardized testing when it determines disability for people who have a mental disorder.

The original public comment period ended on November 17th, but Social Security will reopen the comment period to provide an additional 15 days from the date of publication of the Federal Register notice to allow additional comment on our proposed policy regarding the use of standardized tests.

To read the entire set of proposals, the new notice about the proposed rule on testing, and all of the public comments, go to www.regulations.gov and use the search function to find Docket No. SSA-2007-0101.

Note that there is no talk of clarifying what was meant by the change in the "B" criteria or the changes in the mental retardation listings.

The standardized testing language startled me at first but eventually I concluded that Social Security had not meant anything much by it. Other than for mental retardation and brain damage there simply are not any testing instruments for mental illness that Social Security could possibly justify using.

Keep your eyes on what Social Security does with the "B" criteria and the mental retardation listings. That's where the story is here. Giving ground on one point that you never really cared about can be a good way of defusing criticism on other points that you really do care about. I do not think that Social Security planned this but they do seem to have latched onto this as one way of disarming critics, particularly NAMI.